The Alcohol Wholesaler Registration Scheme was introduced on 01 January 2016 by HM Revenue and Customs to tackle alcohol fraud.

The scheme will apply to existing and new wholesalers of alcohol trading at or after the point at which excise duty has become payable. From April 2017, all businesses who trade in or retail alcohol will need to make sure that any UK Wholesalers that they buy from are registered with HMRC. The type of businesses who will be affected includes alcohol wholesalers including microbrewers and small producers, brokers, auctioneers and alcohol retailers.

From 01 January 2016, HMRC will start to review all Alcohol Wholesaler Registration Scheme applications to decide whether businesses are fit and proper to be accepted onto the register. Where a business fails the fit and proper test HMRC will remove its right to trade in wholesale
alcohol.

From April 2017, all businesses who trade in or retail alcohol will need to make sure that any UK wholesalers that they buy from are registered with HMRC. HMRC is to provide an online service so that trade buyers can ensure wholesalers they buy from are registered with HMRC.

Alcohol wholesalers need to submit their Alcohol Wholesaler Registration Scheme application between 01 January and 31 March 2016.
New wholesalers who commence trading after 31 March 2016 must apply for registration at least 45 days before they wish to start trading. They will not be able to start trading until HMRC have ensured their fit and proper status otherwise, they will be subject to a penalty.

HMRC will be looking to make sure there is no evidence of illicit trading, that the person running the business hasn’t previously been involved in any significant revenue non-compliance or fraud; that there are no connections between the business or key persons involved in the business with other known non-compliant or fraudulent businesses; that key persons in the business have no unspent criminal convictions which HMRC consider relevant for example offences involving any dishonesty or links to organised criminal activity; that the application is accurate and complete and there has been no attempt to deceive; that there have not been persistent or negligent failures to comply with any HMRC record keeping requirements; that the applicant hasn’t previously attempted to avoid registration and traded unauthorised; that the business has provided sufficient evidence of its commercial viability and/or its credibility; that there are no outstanding unmanaged HMRC debts or a history of poor payment and that the business has in place satisfactory due diligence procedures to protect it from trading in illicit supply chains.

Where a business fails the scheme’s fit and proper test HMRC may remove a business’s right to wholesale alcohol at any time during the introduction of the scheme.

Penalties for wholesalers trading without having submitted their application to HMRC will start from 01 April 2016 and penalties for trade buyers who purchase alcohol from unregistered wholesales will start from 01 April 2017. In addition, any alcohol found on the premises of unregistered businesses may be seized whether or not the duty has been paid.

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